What happens if I don't arrange the tyre passport for my fleet?
As a fleet manager, you usually purchase tyres through a supplier, wholesaler or leasing company. In that situation, it is usually not your company, but that party, that is the manufacturer who must have the digital product passport prepared. If you do nothing and silently assume that someone else will take care of this, you run the risk that when inspected or when vehicles are transferred, you cannot produce documentation, even though you may be asked for it.
The situation changes as soon as you purchase tyres yourself outside the standard EU supply chain, for example directly from a manufacturer outside the Union for a large fleet. Then your company may itself acquire a role in the supply chain that carries obligations. What that role precisely is depends on the regulation and on how the procurement is organised; that is a question for the official text or for a lawyer, not something that is established in this article.
Who is actually responsible in the tyre supply chain
The regulation works with roles: a manufacturer, an importer, a distributor, and sometimes a party that by its actions itself becomes classified as a manufacturer. For most fleet managers, they obtain tyres from a distributor or through a lease contract, and that party is responsible for the passport. If you are unsure about your own role, that is a question you can look into separately; in a few questions see roughly where your company stands provides a first indication there, without it being a legal judgment.
What practically goes wrong if no one takes responsibility
The most common risk is not a fine, but delay and uncertainty at the moment when you need the passport. Think of a leasing company that requests tyre documentation when returning vehicles, an insurer that requests maintenance data after an incident, or a client that in a tender asks whether your fleet complies with applicable product information requirements. If you cannot demonstrate that, it costs time and trust, even if no direct infringement is established.
A second risk lies in your own administration. Fleets often work with multiple tyre suppliers and changing contracts. Without a clear agreement on who maintains the passport, there is a risk that no one does, or that data is recorded twice and inconsistently. That is not a matter of ill will, but of a gap in the allocation of responsibility.
The relationship with the leasing company, insurer and client
From a contractual perspective, it is advisable to specify when entering into or renewing a lease contract or maintenance agreement who will arrange the tyre passport and who will manage the QR data carrier. This is not in itself a legal obligation, but it prevents you from only finding out that no one has taken care of this when a customer, insurer or supervisor asks for it. More on how such a connection works in practice can be found in the explanation of where the passport data comes from.
What a supervisor can do
Supervisors in the Netherlands and the EU look in market surveillance at the party designated as the manufacturer, and at whether the required product information is available and traceable. How strictly that is checked and with what consequences is not something this article makes a prediction about; that is up to the supervisor themselves and may differ depending on the situation. For the most frequently asked questions about supervision and who has what role, consult the overview of frequently asked questions is a logical starting point.
How you limit the risk without becoming a lawyer
You don't need to know all the details of the regulation to limit the risk for your fleet. It already helps to document per supplier who takes care of the passport, to make that question standard in new contracts, and to get a general picture yourself of your role in the chain. For a broader overview of the topics involved, selected per situation, you can consult the knowledge base.
Would you like to get a short and free picture first of where your company roughly stands, without having to read all the rules at once? Do the free quick-scan or browse through the topics in the knowledge base; both will give you a concrete starting point within half an hour.